FACTS:

The properties in dispute were formerly part of the notorious Maysilo Estate left by Gonzalo
Tuason, the vastness of which measures 1,660.26 hectares, stretching across Caloocan City,
Valenzuela, and Malabon, covered by five (5) mother titles or Original Certificate of Title (OCT).
One of the mother titles is OCT No. 994, the mother title in dispute. Later on, smaller lots
forming part of the Maysilo Estate were sold to different persons. Several subsequent
subdivisions, consolidations, and one expropriation of the Estate, spawned numerous legal
disputes, living-up to the name "Land of Caveat Emptor."1 One of these disputed lots was Lot 26,
the property subject of this litigation.

The conflict arose due to an overlapping of the properties of CLT and Hi-Grade, which
prompted CLT to file a case for Annulment of Transfer Certificates of Title, Recovery of
Possession, and Damages before the Regional Trial Court (RTC) of Caloocan City.

VERSION OF HI-GRADE

VERSION OF CLT

RTC: Hi-Grade's title, the older title, cannot prevail over CLT's title because it suffers from
patent defects and infirmities. Although Hi-Grade paid realty taxes on the subject properties, it
is not considered as a conclusive proof of ownership.

CA: REVERSED RTC DECISION

Upholding the validity of TCT Nos. 237450 and T-146941 of appellant Hi-Grade Feeds
Corporation.

During the pendency of the appeal, Hi-Grade filed a Motion to Admit and Take Judicial Notice
of Committee Report on Senate Inquiry into Maysilo Estate Submitted by the Committees on
Justice and Human Rights and on Urban Planning, Housing and Resettlement (Senate Report)
on 1 July 1998. The Court of Appeals granted the motion in a Resolution 9 dated 31 August 1998.
Included in the Resolution, however, is a statement that although the Court of Appeals takes
judicial notice of the Senate Report, the Court of Appeals is not bound by the findings and
conclusions therein.

In the meantime, the Office of the Solicitor General (OSG), on behalf of the Republic and in
representation of the Administrator of the Land Registration Authority, filed a Petition for
Intervention dated 25 August 1998. The OSG averred that its intervention is indispensable as it
is pursuant to its duty to preserve the integrity of the Torrens system of registration and to
protect the Assurance Fund, in connection with which it can initiate necessary actions for the
annulment of titles irregularly and fraudulently issued. The Court of Appeals granted the OSG
motion. The Court of Appeals resolved the issue on intervention in the appealed Decision dated
18 June 2003. According to the Court of Appeals, due to the magnitude and significance that
will affect the stability and integrity of the Torrens system, the State has sufficient interest in the
case.
ISSUE:

Whether or not the Court of Appeals committed a reversible error when it took judicial
notice of the Senate Report

RULING:

CLT avers that taking judicial notice of the Senate Report is a violation of the Rules of Court and
CLT's right to due process. First, the Senate Report is inadmissible and should not be given any
probative value because it was obtained in violation of Rule 132 of the Rules of Court,
considering that the Senate Report is unauthenticated and is thus deemed hearsay evidence.
Contrary to the mandatory procedure under Rule 132 of the Rules of Court, which requires
examination of documentary and testimonial evidence, the Senate Report was not put to proof
and CLT was deprived of the opportunity to conduct a cross-examination on the Senate Report.
And it is also contended that the right of CLT to due process was violated because the
proceedings in the Senate were conducted without notice to CLT. Finally, the admission in
evidence of the Senate Report violated the time-honored principle of separation of powers as it
is an encroachment into the jurisdiction exclusive to the courts.

CLT misses the point. Taking judicial notice of acts of the Senate is well within the ambit of the
law. Section 1 of Rule 129 of the Revised Rules on Evidence provides:

SECTION 1 . Judicial notice, when mandatory. — A court shall take judicial notice, without the
introduction of evidence, of the existence and territorial extent of states, their political history,
forms of government and symbols of nationality, the law of nations, the admiralty and maritime
courts of the world and their seals, the political constitution and history of the Philippines, the
official acts of legislative, executive and judicial departments of the Philippines, the laws of
nature, the measure of time, and the geographical divisions, (1a) (Emphasis and underscoring
supplied)

Judicial notice is the cognizance of certain facts that judges may properly take and act on
without proof because these facts are already known to them; 13 it is the duty of the court to
assume something as a matter of fact without need of further evidentiary support. 14 Otherwise
stated, by the taking of judicial notice, the court dispenses with the traditional form of
presentation of evidence, i.e. the rigorous rules of evidence and court proceedings such as cross-
examination.

The Senate Report, an official act of the legislative department, may be taken judicial notice of.

CLT posits that the Court of Appeals violated the time-honored principle of separation of
powers when it took judicial notice of the Senate Report. This contention is baseless. We adopt
the pronouncements of this Court in Angeles v. The Secretary of Justice:

To be sure, this Court did not merely rely on the DOJ and Senate reports regarding OCT No.
994. In the 2007 Manotok case, this Court constituted a Special Division of the Court of Appeals
to hear the cases on remand, declaring as follows:
Since this Court is not a trier of fact[s], we are not prepared to adopt the findings made by the
DOJ and the Senate, or even consider whether these are admissible as evidence, though such
questions may be considered by the Court of Appeals upon the initiative of the parties, x x
x The reports cannot conclusively supersede or overturn judicial decisions, but if admissible
they may be taken into account as evidence on the same level as the other pieces of evidence
submitted by the parties. The fact that they were rendered by the DOJ and the Senate should
not, in itself, persuade the courts to accept them without inquiry. The facts and arguments
presented in the reports must still undergo judicial scrutiny and analysis, and certainly the
courts will have the discretion to accept or reject them. 17 (Emphasis and underscoring
supplied)
Thus, the Senate Report shall not be conclusive upon the courts, but will be examined and
evaluated based on its probative value. The Court of Appeals explained quite pointedly why
the taking of judicial notice of the Senate Report does not violate the republican principle. Thus:

However, the question of the binding effect of that Report upon this Court is altogether a
different matter. Certainly, a determination by any branch of government on a justiciable matter
which is properly before this Court for adjudication does not bind the latter. The finding of the
Senate committees may be the appropriate basis for remedial legislation but when the issue of
the validity of a Torrens title is submitted to a court for resolution, only the latter has the
competence to make such a determination and once final, the same binds not only the parties
but all agencies of government.
That there is such a document as the Senate Report was all that was conceded by the Court of
Appeals. It did not allow the Senate Report to determine the decision on the case.